Report – A Scrap Game: Impacts of the EU Carbon Border Adjustment Mechanism

  The Carbon Border Adjustment Mechanism (CBAM) was formally adopted on 17 May 2023, two years after the initial proposal by the European Commission. We are now in the midst of the CBAM transitional period and negotiations are continuing for its full entry into...

CEPS-Sandbag Joint Op-Ed – The EU should lead the green steel race… Or it could be left behind in the dust

A wave of low-carbon steel projects should be launched across the EU by 2030 but how commercially viable they are is still to be seen. According to Agora Industry, two critical factors underpin this uncertainty: a carbon price below EUR 150 per tonne of CO2 emissions...

From Niche to Mainstream: Shaping Demand for Green Steel

This report on the demand for green steel examines the impact of steel production using low-carbon technologies further down the value chain.   Key Takeaways Due to weak carbon prices and high electricity costs, producing green steel incurs in a premium, which...

Joint letter calling for separate emissions reductions and permanent CDR targets in EU 2040 climate framework

Sandbag co-signed an open letter sent to the European Commission by 114 leading academics, businesses, civil society organisations and research institutions urging the EU to set explicit and separate targets for greenhouse gas emissions reductions, land-based carbon...

Update of the EU ETS free allocation rules: Polluting for free during a climate crisis

In this joint op-ed, first featured in Carbon Pulse, Sandbag policy officer Aymeric Amand and Carbon Market Watch policy expert Lidia Tamellini examine the revision of the Free Allocation Regulation. The EU Emissions Trading System (ETS) is one of the core EU...

European Commission lets recycled steel down in regulation proposal

Sandbag and 12 other organisations – representing important environmental NGOs, think tanks and the European recycling industry – have co-signed a letter addressed to Members of the European Parliament and Members of Coreper 1 in response to the European Commission’s...

Sandbag is a non-profit climate change think tank that uses data analysis and targeted advocacy campaigns to improve EU climate policies

Our work focuses on EU policies such as the EU Emissions Trading System, carbon border adjustment mechanisms, and emissions reductions in industrial sectors. We believe in Europe’s ability to lead by example in climate aciton as well as to use its large market and stimulate technological competition as an incentive for others to follow. However we are also aware of the risk of Europe failing to meet its own commitments, which is why we want EU climate policies and regulations to be as effective and robust as possible.

Our Work

Carbon Pricing

Our research on the EU ETS and emission allowances, advocating for efficient carbon pricing mechanisms and concrete ways to drive emission reductions.

Industry

Exploring the potential of electrification, circularity, and innovative technologies to decarbonise hard-to-abate sectors like steel, aluminium, and cement.

CBAM

Supporting a strong CBAM to phase out the allocation of free emission allowances, address carbon leakage, and accelerate global climate action.

Climate Financing

Our analysis of EU funding initiatives driving climate innovation and industrial decarbonisation. Ensuring revenues from the EU ETS and CBAM are well spent.

Data Tools

Our data visualisation and simulation tools, allowing EU policymakers to gain unique insights and implement informed climate policies.

Publications

Key dates in the calendar (in progress)

In bold: legislative date

2024 – Emissions from maritime transport are covered in EU ETS for cargo and passenger ship over 5,000 gross tonnage (40% of the emission are covered in 2024, 70% in 2025, and in 2026 it will be 100% for ship travelling within the EU and 50% for ships travelling between EU and non-EU ports)

2024 – Installations for the incineration of municipal waste above a certain threshold are required to monitor and report their emissions in the EU ETS

4 April 2024– Publication of the revised EU ETS Free Allocation Rules in the Official Journal of the European Union

Early May 2024 – Publication of the 2023 EU ETS compliance data

16 May 2024 – Climate Change Policy Expert Group meeting (EU ETS formation)

13 June 2024 – Climate Change Policy Expert Group meeting (EU ETS formation)

By 30 June 2024 – Implementing Regulation laying down the detailed rules for calculating CORSIA-related offsetting under Article 12(7) of EU ETS Directive

June 2024 (TBC) – Public consultation & publication of draft Delegated Act on the inclusion of permanent CCU in the EU ETS

11 July 2024 – Climate Change Policy Expert Group meeting (EU ETS formation)

By 31 August 2024 – Implementing Regulation laying down the detailed rules for monitoring and reporting the non-CO2-effects of aviation (Article 14(5) of EU ETS Directive)

September 2024 – Climate Change Policy Expert Group meeting (EU ETS formation)

November 2024 – Climate Change Policy Expert Group meeting (EU ETS formation), vote in CCC on ETS

December 2024 – Climate Change Policy Expert Group meeting (EU ETS formation), envisaged adoption

2024 – Inclusion of methane and nitrous oxide emissions in the monitoring, reporting and verification of emissions from maritime transport

By the end of 2024 – Adoption of a Delegated Act on a support mechanism for the use of eligible fuels, which will distribute emission allowances to cover the price difference to kerosene

By the end of 2024 – Delegated Act amending the ETS Monitoring & Reporting Regulation to include requirements for reporting the use of CORSIA eligible fuels and unit cancellation

2025 – Beginning of the monitoring and reporting of emissions covered under ETS2

Q1 2025 – Delegated Act on Free Allocation Rules in force

By 1 January 2025 – Regulated entities covered by the ETS2 are required to hold a greenhouse gas emissions permit and an approved plan for monitoring their annual emissions

June 2025 – Social Climate Plans to be submitted by Member States to the European Commission

2026 – Full auctioning of emission allowances to aviation

2026 – Social Climate Fund enters into force

By 2026 – Analysis on the feasibility of including municipal waste incineration installations in the EU ETS from 2028

By early 2026 – The EC creates an EU-wide investment atlas of potential CO2 storage sites

2026 – Inclusion of methane and nitrous oxide emissions from maritime transport in the EU ETS

By 21 December 2026 – Report by the EC on the feasibility and economic, environmental and social impact of the inclusion of ship between 400 and 5,000 gross tonnage

2027 – ETS2 becomes fully operational (postponed to 2028 in case of exceptionally high gas or oil prices in 2026)

2039 – The EU ETS cap reaches zero

In bold: legislative date

23 April 2024 – CBAM Expert Group meeting

1 July 2024 – CBAM rules on the verification of embedded emissions; maximum use of default values (when reporting embedded emissions) goes down from 100% to 20%

31 July 2024 – Deadline to finalise 2023 CBAM declarations

Q3 2024 -Implementing Act  :

  • Authorisation of CBAM declarants (two separate acts)
  • Technical arrangements of CBAM Registry

Q4 2024 and Q5 2025 – Implementing Act and Delegated Act: accreditation of verifiers (IA+DA) & verification principles (IA)

Q4 2024 – Delegated act : sale and re-purchase of CBAM certificates

Q4 2024 – Implementing Act :

  • Goods brought to the continental shelf or the exclusive economic zone
  • Communication and information of imported goods at the border

Q4 2024 -Report by the EC on recommendations for the inclusion of other relevant downstream products of the goods listed in Annex I, including a methodology

Q1 2025 : Final deliverable of studies by the Commission on:

  • Finalisation of default values
  • Rules for monitoring, reporting and verification (MRV) of embedded emissions during the definitive period & adjustment for free allocation
  • Adjustment for carbon price paid abroad

28 February 2025 – Deadline to finalise 2024 CBAM declarations

Q2 2025 – Implementing Act

  • CBAM Declaration
  • Calculation of embedded emissions
  • Carbon price paid in third countries
  • Price of CBAM certificates
  • Adjustment for free allocation

Q2 2025 : Final deliverable of studies by the Commission on:

  • Scope extension to indirect emissions
  • Scope extension upstream and for new goods and transport services
  • Scope extension to downstream goods

Q4 2025 & Q3 2028- Report by the EC on an assessment of the reports submitted by third countries on the fulfilment of conditions to be exempted from CBAM for electricity as a CBAM good

Q4 2025 – Report on the application of CBAM, including on possibility to extend the scope

Q4 2025 and every year thereafter – Report on impact on LDC’s (decarbonisation of manufacturing industries)

31 December 2025: the CBAM is implemented as a transitional measure, with obligations limited to monitoring and reporting

1 January 2026 – start of the definitive period, CBAM implementation :

  • the Commission is empowered to modify the list of goods subject to the CBAM for anti-circumvention purposes
  • Importers will need to declare each year the quantity of goods imported into the EU in the preceding year and their embedded GHG. They will then pay for it with the corresponding number of CBAM certificates

28 February 2026 – Deadline to finalise 2025 CBAM declarations

Q3 2027 – Report by the EC on the delegation of power to adopt delegated acts

Q4 2027 and every two years thereafter – Reports by the EC on CBAM functioning, its impacts (internal market, consumer prices, industries, trade) and possible adjustments in application (scope, governance)

Q4 2027 and every two years thereafter – Report by the EC on impact on exports

In bold: legislative date

30 April 2024 – Results of the first auction of the European Hydrogen Bank

June 2024 – Entry into force of the Gas Package

2024 – Creation of the European Network of Network Operators for Hydrogen (ENNOH)

Between 2024 and 2026 – ENNOH and European Network of Transmission System Operators for Gas (ENTSOG) will work together

December 2024 – Delegated Act on the definition of the methodology for the certification of low carbon gas

End of 2024 – Second auction of the European Hydrogen Bank

End of 2024 – At least 6 GW of renewable hydrogen electrolysers are supposed to have been installed in the EU

2025 – Report by the EC on the production, transport and uptake of renewable hydrogen in industry and transport.

June 2025 – Agency for the Cooperation of Energy Regulators (ACER) recommendations on inter-temporal cost allocation for Transmission System Operators (TSOs) and Distribution System Operator (DSO)

June 2026 – Member States to ensure that hydrogen TSOs are unbundled in accordance with the rule for gas TSOs

June 2026 – Maximum timeline for transposition of the Gas Package directive by Member States

1 January 2027 – European transmission network operator for hydrogen (ENNOH) to be fully operational and independent

2028 – Update by Member States of their Network Decommissioning Plans (NDPs) for their unused gas networks.

By 31 December 2030 – Review by the EC on the methodology for low carbon gases

2034 – ACER’s report on the impact of the unbundling rules for hydrogen DSO and TSOs

2025 – Communication by the EC on the implementation of unbundling rules for hydrogen TSOs and DSOs

By 31 December 2030 – Assessment of whether facilities that begin operation from 1 January 2031 should demonstrate huger greenhouse gas emission saving

1 January 2033 – End of the fixed tariff for hydrogen at interconnection point, each national regulator will now fix their own tariffs

2030 – At least 40 GW of renewable hydrogen electrolysers are supposed to have be installed in the EU

June 2024 (TBC) – Public consultation & publication of draft Delegated Act on the inclusion of permanent CCU in the EU ETS

By 2025 : The European Commission develops a step by step guidance for permitting processes for net-zero strategic projects for CO2 storage

By early 2026 :

  • The EC creates an EU-wide investment atlas of potential CO2 storage sites
  • A platform for demand assessment ad demand aggregation for C02 transport or storage services
  • The EC assesses with the EU ETS 2026 review if and how the CO2 removed from the atmosphere and safely and permanently stored could be accounted for and covered by emissions trading

2027 – The EU Innovation Fund, which supports carbon capture and storage projects, becomes operational

2030 – By this year, the EU plans to have available capacity to annually store 50 million tonnes of CO2

In bold: legislative date

May 2024 – Biochar Technical Scoping Paper by the Commission

19 June 2024 – Online workshop for Biochar by DG Clima (European Commission)

9 July 2024 – Online workshop for peatland by DG Clima (European Commission)

September 2024 – Online workshop on agriculture and forestry, and another one on bio-based building by DG Clima (European Commission)

September 2024 – Stakeholders workshop on rules for verification and registries by DG Clima (European Commission)

September 2024 – Draft methodologies for BECCS and DACSS, Strawman methodology biochar

October 2024 – Fifth Expert Group meeting on the CRCF regulation

2024 and 2025 – Workshops on novel removals and financing options for removals by DG Clima (European Commission)

2025 Delegated acts for firsts certification methodologies and implementing acts for verification and registry rules

By 31 July 2026 – EC report on how and if carbon removals could be accounted for and integrated into the EU ETS

2028 – CRCF certification methodologies finalised

 

In bold: legislative dates

2024 – Decrease of 25% in free allocation to the aviation sector

By 30 June 2024 – Implementing Regulation : Detailed rules for calculating CORSIA-related offsetting under Article 12(7) of EU ETS Directive

By 31 August 2024 – Implementing Regulation : Detailed rules for monitoring and reporting the non-CO2-effects of aviation (Article 14(5) of EU ETS Directive)

By the end of 2024 – Delegated Act : Support mechanism for the use of eligible fuels, which will distribute emission allowances to cover the price difference to kerosene

By the end of 2024 – Delegated Act : amending the ETS Monitoring & Reporting Regulation to include requirements for reporting the use of CORSIA eligible fuels and unit cancellation

2025: Implementing decision on the list of credits eligible for CORSIA offsetting under the ETS Directive (Article 11a(8))

March 2025 – First reporting by airlines of their fuel use (covering 2024)

2025 – Monitoring and reporting by aircraft operators of non-CO2 effects

2025 – Decrease of 50% of free allocation to the aviation sector

2026 – European Commission to publish results on non-CO2 effects of air transport

2026 – European Commission to carry out an assessment of CORSIA to see if it’s sufficiently delivering on the goals of the Paris Agreement.

2026 – Full auctioning of emission allowances to aviation (phase-out of free allowances to the aviation sector)

2027 – EU carbon pricing may start to apply to international flights, depending on the conclusion of the assessment of CORSIA’s efficiency to meet the goals of the Paris Agreement

 

 

In bold: legislative dates

9 April 2024 – Closing of the 2023 Innovation Fund call

11 June 2024 – Stakeholder Consultation on the 2024 Innovation Fund Calls for Proposals

12 June 2024 – Stakeholder Consultation on the draft Terms and Conditions for the second renewable hydrogen auction

27 June 2024 – Innovation Fund Expert Group meeting

TESTIMONIALS

Sandbag is recognised as a top global climate think-tank

An inspirational idea that promises to make a real and positive difference… and a wonderful opportunity to help sort out the climate mess we’ve all created. Prof. Chris Turney is the author of Ice, Mud and Blood: Lessons from Climates Past
Chris Turney

Professor, University of Exeter

Sandbag is playing a crucial role in making sure that Europe’s cornerstone climate policy actually does its job.
Caroline Lucas

United Kingdom MP

Sandbag… strikes a balance between underlining the merits of the EU ETS and criticising the weaknesses.
Connie Hedegaard

Former European Commissioner

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